VIEWS: 36 PAGES: 3 POSTED ON: 2/25/2010
ANTI MONEY LAUNDERING POLICY. 1. Introduction 1. Changes to the legislation concerning money laundering (the Proceeds of Crime Act 2002 and the Money Laundering Regulations 2003), have broadened the definition of money laundering and increased the range of activities caught by the statutory framework. As a result, the new obligations now impact on areas of University business and require universities and colleges to establish internal procedures to prevent the use of their services for money laundering. 2. Scope of the Policy 1. This Policy applies to all University employees and aims to maintain the high standards of conduct which currently exist within the University by preventing criminal activity through money laundering. The Policy sets out the procedures which must be followed (e.g. the reporting of suspicions of money laundering activity) to enable the University to comply with its legal obligations. 2. The Policy complements the University’s Anti-Fraud and Anti- Corruption Strategy. 3. What is Money Laundering? 1. The term Money Laundering includes concealing, disguising, converting, transferring or removing criminal property from the UK, plus acquiring, using or possessing criminal property, or entering into arrangements to help another person in the acquisition, retention, use or control of criminal property. 2. Criminal property is a person's benefit from criminal conduct where the alleged offender knows or suspects that the property constitutes or represents such a benefit. It is specifically provided in the legislation that concealing or disguising criminal property includes concealing or disguising its nature, source, location, disposition movement or ownership or any rights with respect to it. 3. It does not have to be in the UK; criminal conduct is conduct that would be an offence in the UK if it is committed there, i.e. it can be committed abroad and still be reportable in the UK. 4. What are the obligations of the University? 1. The Money Laundering Regulations 2003 came into force on 1 March 2004, and under the terms of the Regulations the university must, when engaged in “relevant business”, (as defined in Reg.2(2) of Money Laundering Regulations) adopt procedures noted in 4.2 – 4.5 below. For the university these procedures must be followed for any sales of goods involving acceptance of a total cash payment of €15,000 or more. (This excludes tuition fees as the provision of education for a fee is the provision of a service). For all other transactions please see para. 4.5 below only. 2. Appoint a Money Laundering Officer (MLRO) to receive disclosures from employees of money laundering activity. The MLRO for the university is the Head of Finance Mr Kevin Wright. 3. Be satisfied as to the identity of its customer. When dealing with business, the use of official stationery and invoices is normally sufficient to confirm the identity of the customer. When dealing with individuals, we should obtain photographic evidence such as a passport or driving licence. 4. Maintain adequate records of the transaction and identity of its customer, and where appropriate documentation confirming the identity of the customer, and a full audit trail of the transaction/(s), must be retained for a period of no less than 5 years. 5. Have a mechanism for reporting possible indications of money laundering. Any member of staff who has reason to believe money laundering has taken place, or who has concerns or suspicions regarding possible indications of money laundering must disclose this to Mr Kevin Wright without delay. If Mr Kevin Wright considers the information to give knowledge or suspicion of money laundering, he must forward the information to the Serious Organised Crime Agency. Updated 14/12/06.
Pages to are hidden for
"ANTI MONEY LAUNDERING POLICY"Please download to view full document